CMS Payment Reform: Your Voice Is Needed by September 14

**What happens when the people delivering healthcare actually participate in deciding how that care is valued?** Right now, we have an opportunity to do exactly that. CMS is accepting public comments on the CY 2027 Medicare Physician Fee Schedule proposed rule, and the deadline is **September 14, 2026**. If you are a U.S.-based occupational therapist, physical therapist, speech-language pathologist, or another rehabilitation or allied health provider, this is a moment to pay attention and participate. Read the CMS CY 2027 Medicare Physician Fee Schedule proposed rule Submit a public comment through Regulations.gov Search for **CMS-1848-P** when submitting your comment. Why this matters Payment policy is about much more than reimbursement rates. It influences what healthcare systems prioritize, how services are structured, what work is considered valuable, and what kinds of care are realistically available to patients. For rehabilitation providers, there can be a significant gap between the work that actually produces meaningful outcomes and what can be easily represented through a billing code. Think about what goes into a complex rehabilitation encounter. There is the assessment itself, but also the clinical reasoning behind it. There is communication with caregivers and other providers, environmental analysis, education, risk management, adapting interventions to the individual, coordinating care, and making decisions based on information that may not be captured by a single diagnosis or procedure code. For many of us, these are not extras added onto the work. **They are the work.** That makes this comment period important. Rather than simply saying that reimbursement is too low, we have an opportunity to explain what current payment structures fail to capture and what that means for patients, providers, and the healthcare system. What is changing? The CY 2027 proposed rule includes changes and requests for input related to how Medicare services are coded and valued, including the Practice Expense methodology and aspects of care management and remote monitoring. These are technical policy issues, but the questions underneath them are surprisingly practical: What does it actually take to provide good care? What resources are required? What kinds of clinical work happen outside the most visible portion of an encounter? How should payment systems recognize complexity, coordination, clinical reasoning, and the resources required to manage patients over time? These are questions rehabilitation providers have direct experience answering. OT Potential’s Sarah Lyon and colleagues have been particularly active in bringing OT and PT perspectives into this conversation. Their proposed recommendations include better differentiation in reimbursement for evaluation complexity and consideration of non-time-based therapist management codes to recognize some of the ongoing clinical work that occurs throughout an episode of care. You do not have to agree with every recommendation to see the value in participating. In fact, this is one of the things I appreciate about the public comment process. It gives us an opportunity to respond to what is actually being proposed, identify what we think is missing, describe unintended consequences, and offer alternatives based on what we see in practice. Start with Sarah Lyon’s episode If you want some context before diving into the policy language, I recommend starting with Sarah Lyon’s recent OT Potential episode on this issue. Listen to the OT Potential episode on YouTube The episode provides a useful overview of the current opportunity and the work underway to bring rehabilitation perspectives into the Medicare payment conversation. OT Potential has also created a **2027 CMS Comment Template for OT and PT care**, which makes the process considerably easier if you are staring at Regulations.gov wondering where to begin. Access the OT Potential CMS Comment Template The template provides language you can adapt, along with references and guidance for submitting your comment. I would encourage you to personalize it rather than simply submitting the exact same language as everyone else. Your own experience is what makes the comment valuable. What can you contribute? Start with the part of the system you know. Maybe you work with patients whose needs are more complex than the evaluation code adequately communicates. Maybe much of your clinical expertise involves adapting care to cognition, environment, caregiver capacity, health literacy, routines, transportation, safety, or other contextual factors. Maybe you spend substantial time coordinating with other disciplines and caregivers. Maybe your work involves preventing a problem rather than treating the consequences after it happens. Maybe you have watched a patient avoid an emergency department visit because someone identified a risk early. Maybe you have helped a family safely manage a transition home. Maybe your interdisciplinary team caught something that would have otherwise resulted in a complication or readmission. These experiences matter. They help illustrate something that can get lost when healthcare policy is discussed primarily through codes, utilization data, and reimbursement formulas: **healthcare is delivered by people making decisions in complex environments with other people.** If a payment methodology does not adequately account for the resources required to do that work well, policymakers need concrete examples of what is being missed. Don’t underestimate the value of your clinical perspective You do not need to be a healthcare economist to submit a meaningful comment. You do not need to write a 20-page policy analysis. You do not need to represent your entire profession. A useful comment can be fairly straightforward. Identify the issue you are responding to. Describe what you see in practice. Explain why it matters. Give a concrete example. Then tell CMS what you think should be considered. Instead of simply saying, “OTs need to be paid more,” you might explain how comprehensive occupational therapy assessment requires consideration of cognition, environment, routines, caregiver capacity, safety, equipment, participation, and other factors that may not be adequately represented by the existing valuation structure. Instead of simply saying, “care coordination should be reimbursed,” describe what happens when coordination does not occur. Explain who has to do the work, what information has to be exchanged, what decisions are made, and what can happen to the patient when that work is missing. The more concrete we are, the more useful our comments become. This conversation belongs to all of rehabilitation Although OT Potential’s template focuses on OT and PT, I think there is a larger opportunity here. OTs, PTs, SLPs, and other allied health professionals all see different pieces of the same system. We work across hospitals, outpatient clinics, home-based care, post-acute settings, schools, and community environments. We see where care coordination works and where it breaks down. We see the consequences when payment structures reward one part of the care process while making another part difficult to sustain. That perspective is worth bringing into the conversation. This does not have to become another debate about which profession deserves more. The more useful question is: **What does the patient actually need, who has the expertise to provide it, and does the payment system support that care?** That is a question worth asking across the healthcare continuum. We have until September 14 We spend a lot of time talking about healthcare payment. We talk about productivity. We talk about coding. We talk about documentation. We talk about access. We talk about burnout. We talk about care coordination. We talk about the disconnect between what patients need and what healthcare systems can realistically provide. This is an opportunity to move some of that conversation into the policymaking process. CMS is asking for public input. We have resources to help us understand the proposal. We have templates to help us get started. And we have our own professional experiences. So take an hour. Listen to the episode. Read the relevant sections of the proposed rule. Use the template if it helps. Add your own examples. Submit your comment. **Comments are due September 14, 2026.** Read the proposed rule Listen to the OT Potential episode Use the OT Potential comment template Submit your comment And then share this with another clinician. **We cannot expect payment systems to recognize the complexity of our work if we never tell policymakers what that work actually involves.** Now is the time to put our clinical experience on the record. This is a public episode. If you would like to discuss this with other subscribers or get access to bonus episodes, visit josiejarvisot.substack.com